The company first faced FCPA charges from the SEC and entered into a deferred prosecution agreement with the Department of Justice in March 2012, agreeing to pay more than $22 million to settle both cases. As part of the SEC settlement, the company agreed to retain an independent compliance consultant to review its FCPA compliance program. After the settlement as the company was implementing recommendations from the independent monitor, the company learned about potential anti-bribery violations in Brazil and Mexico and notified the monitor and the SEC in 2013.
The SEC’s order finds that the company continued to interact and improperly record transactions with a known prohibited distributor in Brazil, and used a third-party customs broker to pay bribes to Mexican customs officials to facilitate the importation and smuggling of unregistered and mislabeled dental products.
To read the entire SEC Press Release please follow this link: $30M for Repetitive FCPA Violations